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Al Jesena - 10 - 1 March 2000 <br /> Draft RI for OU#3 <br /> NCTS, Stockton <br /> can the Navy surmise that there is no longer a source because of the age of the landfills. We <br /> conclude that age has no relevance in this regard. The Navy should refrain from making <br /> conclusions based on the models when actual field data is contradictory. If there is no field data to <br /> support modeling assumptions/conclusions, then the Navy should propose sampling and <br /> monitoring procedures to verify their predictions. <br /> Additional Comments <br /> We recommend that the entire document be organized according to each site. All the tables, maps, <br /> investigation history and conclusions should be organized together in one location. This reorganization <br /> will make it easier to review by the responsible agencies. Furthermore, throughout the document the <br /> Navy makes conclusive statements in management goal sections (i.e., Goal GM-8), which are <br /> contradictory to the Recommendations summary at the end of each site discussion. The Navy should <br /> provide recommendations after each management goal for clarification and easier review by the <br /> responsible parties. The Recommendation section should consolidate conclusions and describe <br /> additional data gaps in support of their assumptions. All assumptions made by the Navy in support of <br /> modeling efforts or conclusions for no further action should be supported by actual verification sampling <br /> and monitoring at each site (i.e., additional soil sampling, discrete groundwater and surface water <br /> sampling, and sediment sampling). <br /> There are numerous major issues that must be resolved in the revised Draft RI Report for OU 43 landfill <br /> sites. If the Navy does not adequately address our concerns we may issue a Cleanup and Abatement <br /> Order under Water Code Section 13304. <br /> We propose that the State (i.e., DTSC, RWQCB, CDF&G) and TTEMI initiate technical meetings in <br /> Sacramento to address these issues. We believe that, in the end, this will save time and money during <br /> the RI phase of the project. <br /> If you have any questions please contact me at(916) 255-3078 or schwabk(a rb5s.swrcb.ca.gov. <br /> /�Vc�l— <br /> Kim A. Schwab <br /> Associate Engineering Geologist <br /> Enclosure(s) <br /> cc: Mr. Randy Adams, Region 1, DTSC <br /> Mr. Ron Rowe, San Joaquin Environmental Health Dept., Stockton <br /> Mr. Scott Flint, Dept. of Fish and Game, Sacramento <br /> Mr. Brad Beeman, NCTS, Stockton <br /> Mr. Jay Jahangiri, Port of Stockton <br /> Ms. Christine Baumgardt, Luce, Forward, Hamilton and Scripps, San Diego <br /> KAS:\CTS Draft R1 OU3.1 <br />